Private Policy

1. General1.1. Our Privacy Policy

Cofred is committed to protecting your information and respecting your privacy. This Privacy Policy together with the Cofred Account Terms of Use (and any other documents referred to therein) set out the basis on which any personal data we collect from you, or which you provide to us, through our website www.cofredgh.com (“Website”) or in connection with your Cofred Account (as defined in the Cofred Terms of Use) will be processed by us. When you complete any form, speak with our staff or submit any details to us or using our Website, we will collect, use and disclose your personal information in the manner described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data, how we use it and how we will treat it. If you do not agree with this Privacy Policy, please do not use our services.

1.2. Changes to this Privacy Policy Any changes we make to this Privacy Policy in the future will be posted on this page. Any new Privacy Policy will be effective from the time that it is posted on the Website. We reserve the right to make changes to our Privacy Policy at any time, without notice, where such change is required by applicable legislation. If we are going to use your personal data in a manner that is different from the uses set out below, we will notify you by email. You may object to any new use or change in use of your personal data by contacting us as set out in section 10 (Contact Us) below. We will treat such objection as a notice to terminate your Cofred Account which will be closed in accordance with the Cofred Account Terms of Use.

2. Information We Collect2.1. Information We Collect from You We may collect and process the following data about you: your full name, address, email address, telephone number, date of birth and bank or payment card details and any proof of your identity and/or address that we may request, details of any transactions you carry out through our Website using your Cofred Account and of the fulfillment of your requests, details of any bank account (including, but not limited to, account holder, account name, account number, sort code (if any), online banking PIN, Transaction Authentication Number “TAN” and password, available balance and transaction history of your bank account,), details of any credit, debit or other card used by you for transactions, your participation in any promotion sponsored by us, correspondence that you send us, calls that we make to you or you make to us, surveys that you complete, information collected through cookies – please see section 9 Cookies for more details, your IP address, log-in times, operating system and browser type, details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website.

2.2. Information We Collect from Third Parties about You In order to fulfil our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies, including your financial history, county court judgements and bankruptcies, from credit reference and fraud prevention agencies when you open a Cofred Account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks. Please refer to our Money Laundering Policy for further details.

3. How We Use Your Information We use information held about you in the following ways: to operate and administer your Cofred Account and to provide services that you have requested, to carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your nominated bank account to make such payments, to allow you to participate in interactive features of the Website, to notify you about changes to our service(s), to improve our internal customer training, to comply with financial services regulations including retention of financial information and transactions, for financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, for customer service, including answering questions and responding to feedback and complaints, to enhance the security of our services, to ensure that content on our Website is presented in the most effective manner for you and for your computer, and to provide you with information, products or services that you request from us or which we feel may interest you.

4. Storing Your Personal Data4.1. Where is it Stored? The data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") for the reasons set out below: if this is necessary for providing you with the services you request. For example if you transfer funds to a merchant that is not located in the EEA, it will be necessary to send your details to that merchant, where our group companies, some of whom are based in the USA, store or process your data in accordance with our internal operational requirements and procedures in order to administer the services you require or in connection with anti-fraud measures, where you have consented to receive marketing material from our group companies, where our anti-fraud agencies, credit reference agencies and other service providers are based outside the EEA and require access to your data to perform their obligations to us and provide services to you, if you have been referred to us by a third party and that third party is entitled to a commission payment – for further detail see section 5.4. We have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy no matter where it is located.

4.2. Security We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your Cofred Account, all internet communication is secured using Secure Socket Layer (SSL) technology with high security 128bit encryption, certified by Verisign Secured. However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your Cofred Account or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Please read our Cofred Account Terms of Use for further information on how to keep your Cofred Account safe. Details of how to contact Customer Services are available from the “Contact” section of the Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

4.3. Retention We are by law required to retain certain records for a period of at least five years after closure of your Cofred Account which will include your personal data such as your name, contact details, customer number and transaction history etc. Otherwise, we will delete and destroy all personal data that we hold about you when you (or we) terminate your Cofred Account. We do not store your online banking login PIN, TAN and password.

5. Disclosure of Your Information5.1. Group Companies We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries who are based in different countries within the EEA and in the USA. This may be necessary in order to, among other things, fulfill your request, process your payment details, provide support services and monitor fraudulent activities.

5.2. Merchants and other Cofred Customers When sending money to another Cofred Account holder or a merchant who you wish to pay we will, at a minimum, pass on your email address to the recipient. Depending on the requirements of the merchant and the type of payment involved, we may also send other personal details such as your name, address and country of residence if the recipients request this information from us in order to improve the payment process, to reconcile payments with the commercial transaction or to conduct their own anti-fraud and anti-money laundering checks.

5.3. Fraud and Credit Reference Agencies When you open a Cofred Account, at intervals of up to every 3 months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your Cofred Account, financial history and transactions as part of our normal business operations with our banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to the email address set out in the Contact Us section below. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information. Please refer to our Money Laundering Policy for further details.

5.4. Other Disclosures We may also disclose your personal information to: a prospective buyer of our business or a buyer of a substantial number of the shares in our business, the police, other lawful enforcement body, regulatory body or court if we are under a duty to disclose or share your personal data , or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others, third parties where you have expressed an interested in receiving information about their goods and services, and third parties who referred you to us initially and to whom we owe a commission payment as a result of the referral. Where the commission payment is based on transaction volumes, numbers or types of transactions, we may share that information with that third party, but we will not disclose the full details of each of your transactions without your further written consent.

6. Communicating With You We may contact you by email to the primary email address registered with your Cofred Account or by telephone to the contact telephone numbers you have provided when registering for your Cofred Account. You can change your primary email address and/or contact telephone number at any time, subject to the provisions of section 8 below. You may also receive system-generated transactional emails such as confirmation of uploads, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your account.

6.1. Newsletters and Marketing As a Cofred Account holder, you will occasionally receive information by email from us, unless you have chosen not to receive such communication, and if you have consented to do so from our group companies too, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you receive newsletters from us and our group companies in the “Profile” section of your Cofred Account or in any newsletter email by clicking on the appropriate ‘opt-out’ link. Please note that you will still receive communication regarding your Cofred Account such as transactional emails or other notification affecting the operation of your Cofred Account or our legal relationship. From time to time we do share aggregated information about our customers’ use of our website and services with other companies for research and analysis purposes, but you cannot be identified from this aggregated information.

6.2. Phishing Phishing is the name given to attempts to steal personal details and financial account details from a website user. “Phishers” use fake or “spoof” emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords. WE WILL NEVER SEND EMAILS ASKING YOU FOR SUCH DETAILS AND OUR STAFF WILL NEVER ASK YOU FOR YOUR PASSWORD. If you do receive such an email or are asked for your password by anyone claiming to work for us please forward the email or report the incident by email to our Data Protection Officer (contact details are at the end of this policy) or by contacting Customer Services.

7. Links to Other Websites Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. Accessing and Updating Your Information If your personal details (such as your name, address, or telephone number) change you must update your details in the “Profile” section of your Cofred Account or by contacting Customer Services via the “Contact” section of the Website as soon as you can. We shall not be liable for any loss arising out of your failure to keep your personal details up to date. Your address and phone number can only be changed once in any 3 month period. In order to deactivate your Cofred Account, please refer to the Cofred Account Terms of Use. You have the right to access information that we hold about you. To do so, please contact us at the address given at the end of this policy. Access may be subject to a fee of up to GHs50.00.

9. Cookies9.1. General A cookie is a small data file which contains information that is transferred to the hard drive of the device from which you access our site. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

9.2. Types of Cookies and Consent In order to comply with legislation, we have reviewed the use of cookies on our site and have implemented measures to ensure that you are aware of these cookies and give your consent for placing of some or all of these cookies, except for those which are necessary for the services you have requested (as explained below). In summary, we use the following types of cookies: cookies which are essential for our site to operate, such as those which identify you so you can log into your Cofred Account. These cookies will always be activated, cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your Cofred Account from being hijacked. These cookies will always be activated, cookies that help us to improve our site and to deliver a better and more personalized service to you; cookies that enable us to link to our group companies’ websites; some cookies are not related to us or our group companies. When you visit a page with content embedded from, for example, YouTube or Twitter, you may be presented with cookies from these websites. We do not control the dissemination of these cookies, you should check the third party websites for more information about these cookies.

9.3. Blocking Cookies You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Our system will issue cookies as soon as you visit our site unless you have adjusted your browser setting so that it will refuse cookies.